Updated as of May 15, 2018

 

Institutional Customer Privacy Notice

This Privacy Notice explains how Jennison Associates LLC (“Jennison”) collects, uses and discloses personal information online and offline in connection with: (i) the investment advisory and investment management services (“Services”) we provide to our corporate and institutional customers and (ii) our business relationships with corporate and institutional entities in the ordinary conduct of our investment management business. We refer to the individuals who work for these customers and businesses as “you” in this Notice.


PERSONAL INFORMATION
“Personal Information” is information that identifies an individual or relates to an identifiable individual, such as:

  • Name
  • Postal address
  • Telephone number
  • Email address

We need to collect and process Personal Information in order to provide the requested Services to our customers or to maintain business relationships in order to conduct our investment management business, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services or maintain a business relationship with you.

Collection of Personal Information
We and our agents, affiliates and service providers collect Personal Information in a variety of ways:

  • Through the Services and our Business Relationship with you.
    • We collect Personal Information through the Services and in the ordinary course of our business with you.
  • Offline.
    • We collect Personal Information from you offline, such as when you participate in a transaction or contractual arrangement.
  • From Other Sources.
    • We receive Personal Information from other sources, for example:
      • publicly available databases,
      • your employer, and/or
      • the entity to which we provide the Services and from other third parties.


Use of Personal Information
We and our service providers use Personal Information for the following reasons:

  • Providing the functionality of the Services and fulfilling our customer’s requests. 
    • To respond to inquiries and fulfill requests from our customers, administer their account(s) and manage our relationships; and
    • To verify an individual’s identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts; or conduct online transactions.

We will engage in these activities to manage our contractual relationship with our customers and/or to comply with a legal obligation.

  • Providing our customers with our newsletter and/or other marketing materials and facilitating social sharing. 
    • To inform our customers about products or services which we believe may be of interest.

We will engage in this activity because we have a legitimate interest or with your consent.

  • Accomplishing our business purposes.
    • For business purposes, including data analysis, audits, developing and improving products and services, identifying usage trends and determining the effectiveness of promotional campaigns, and enhancing, improving or modifying our Services
      • To validate authorized signatories when concluding agreements and transactions;
      • To contact individuals in connection with existing transactions and contractual agreements;
      • For risk management, for fraud detection and prevention, including know your customer, anti-money laundering, due diligence requirements, credit checks, compliance with sanction rules, fraud monitoring, and tax reporting;
      • To comply with laws and regulations (including any legal or regulatory guidance, codes or opinions), and to comply with other legal process and law enforcement requirements;
      • To protect the security of accounts and Personal Information; and
      • To send administrative information to you, such as changes to our terms, conditions and policies.

We engage in these activities to manage our contractual relationship with our customers, to comply with a legal obligation, and/or because we have a legitimate interest.

Disclosure of Personal Information
We disclose Personal Information:

  • To our affiliates for the purposes described in this Privacy Notice.
    • A listing of our affiliates can be provided by your client services representative or by emailing: privacy@jennison.com
    • Jennison Associates LLC is the party responsible for the management of Personal Information used jointly
  • To our third party service providers, to facilitate services they provide to us.
    • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services; and
  • To intermediaries and counterparties with which we may have dealings.
    • These can include other insurers, financial institutions, brokers and credit institutions.
  • To customer’s service providers or customers.
    • For our customers, these can include your custodians, fund administrators or consultants.
    • For customer’s service providers, these can include our mutual customers.

Other Uses and Disclosures
We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law.
    • This can include laws outside of the country in which you are based
  • To respond to requests from public and government authorities.
    • These can include authorities outside the country in which you are based
  • To cooperate with law enforcement.
    • For example, when we respond to law enforcement requests and orders.
  • For other legal reasons.
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.


OTHER INFORMATION
“Other Information” is any information that does not reveal a person’s specific identity or does not directly relate to an identifiable individual:

  • Browser and device information
  • App usage data
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other information provided by you that does not reveal a person’s specific identity,
  • Information that has been aggregated in a manner that it no longer reveals a person’s specific identity

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Notice.

Collection of Other Information
We and our service providers collect Other Information in a variety of ways:

  • Through a browser or device.
    • Certain information is collected by most browsers or automatically through devices, such as a Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device
      manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) being used. We use this information to ensure that the Services function properly.
  • Using cookies.
    • Cookies are pieces of information stored directly on the computer being used. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize the user’s experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals.
    • Most browsers allow individuals to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for more information. Declining cookies may cause certain parts of the Services to cease working.
  • Using pixel tags and other similar technologies.
    • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
  • IP Address.
    • IP address is automatically assigned to a computer by an Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive approximate location from IP address.

Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

THIRD PARTY SERVICES
This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS
Your choices regarding our use and disclosure of Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.

You may opt-out from receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by: privacy@jennison.com

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How individuals can access, change or delete their Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by at the Contact Us link below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have the Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of the Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

RETENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with our customer and provide the Services;
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of certain transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 16.

JURISDICTION AND CROSS-BORDER TRANSFER
Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States as detailed in the Disclosure section above. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Personal Information.

If you are located in the European Economic Area (EEA): Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place standard contractual clauses adopted by the European Commission to protect Personal Information. You may obtain a copy of these measures by contacting privacy@jennison.com.

SENSITIVE INFORMATION
Unless we specifically request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO PRIVACY NOTICE
We may change this Privacy Notice. The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the Services. Use of the Services following these changes signifies acceptance of the revised Privacy Notice.

CONTACTING US
Jennison Associates LLC, located at 466 Lexington Avenue, New York, NY 10017 is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Notice.

Any questions about this Privacy Notice, please contact us at privacy@jennison.com or:

Privacy Officer
Jennison Associates LLC
466 Lexington Avenue, 19th
Floor New York, NY 10017

ADDITIONAL INFORMATION FOR THE EEA
Individuals in the EEA also may lodge a complaint with a data protection authority for their respective country or region, or where an alleged infringement of applicable data protection law occurs.

 

 

© 2018 Jennison Associates LLC
Prudential Financial, Inc. of the United States is not affiliated with Prudential plc which is headquartered in the United Kingdom.